The case for unitary taxation with formulary apportionment in the finance sector and the effect on developing nations

In 2013 the OECD released its 15 point Action plan to deal with base erosion and profit shifting (BEPS). In that plan it was recognised that BEPS has a significant effect on developing countries. This is because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote economic growth. To this end, the BEPS project is aimed at ensuring an inclusive approach to take into account not only views of the G20 and OECD countries but also the perspective of developing nations. With this focus in mind and in the context of developing nations, the purpose of this article is to consider a possible solution to profit shifting which occurs under the current transfer pricing regime, with that solution being unitary taxation with formulary apportionment. It does so using the finance sector as a specific case for application. Multinational financial institutions (MNFIs) play a significant role in financing activities of their clients in developing nations. Consistent with the ‘follow-the-client’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. Further, not only are MNFIs persistent users of tax havens but also, more than other industries, have opportunities to reduce tax through transfer pricing measures. This article establishes a case for an industry specific adoption of unitary taxation with formulary apportionment as a viable alternative to the current regime. It argues that such a model would benefit not only developed nations but also developing nations which are currently suffering the effects of BEPS. In doing so, it considers the practicalities of such an implementation by examining both definitional issues and a possible formula for MNFIs. This article argues that, while there would be implementation difficulties to overcome, the current domestic models of formulary apportionment provide important guidance as to how the unitary business and business activities of MNFIs should be defined as well as factors that should be included in an allocation formula, along with the appropriate weighting. While it would be difficult for developing nations to adopt such a regime, it is argued that it would be no more difficult than addressing issues they face with the current transfer pricing regime. As such, this article concludes that unitary taxation with formulary apportionment is a viable industry specific alternative for MNFIs which would assist developing nations and aid independent fiscal soundness.

Direct electrochemical formation of nanostructured amorphous Co(OH)2 on gold electrodes with enhanced activity for the oxygen evolution reaction.

The oxides of cobalt have recently been shown to be highly effective electrocatalysts for the oxygen evolution reaction (OER) under alkaline conditions. In general species such as Co3O4 and CoOOH have been investigated that often require an elevated temperature step during their synthesis to create crystalline materials. In this work we investigate the rapid and direct electrochemical formation of amorphous nanostructured Co(OH)2 on gold electrodes under room temperture conditions which is a highly active precursor for the OER. During the OER some conversion to crystalline Co3O4 occurs at the surface, but the bulk of the material remains amorphous. It is found that the underlying gold electrode is crucial to the materials enhanced performance and provides higher current density than can be achieved using carbon, palladium or copper support electrodes. This catalyst exhibits excellent activity with a current density of 10 mA cm-2 at an overpotential of 360 mV with a high turnover frequency of 2.1 s-1 in 1 M NaOH. A Tafel slope of 56 mV dec-1 at low overpotentials and a slope of 122 mV dec-1 at high overpotentials is consistent with the dual barrier model for the electrocatalytic evolution of oxygen. Significantly, the catalyst maintains excellent activity for up to 24 hr of continuous operation and this approach offers a facile way to create a highly effective and stable material.

Bayesian model comparison in cosmology with Population Monte Carlo

We use Bayesian model selection techniques to test extensions of the standard flat LambdaCDM paradigm. Dark-energy and curvature scenarios, and primordial perturbation models are considered. To that end, we calculate the Bayesian evidence in favour of each model using Population Monte Carlo (PMC), a new adaptive sampling technique which was recently applied in a cosmological context. The Bayesian evidence is immediately available from the PMC sample used for parameter estimation without further computational effort, and it comes with an associated error evaluation. Besides, it provides an unbiased estimator of the evidence after any fixed number of iterations and it is naturally parallelizable, in contrast with MCMC and nested sampling methods. By comparison with analytical predictions for simulated data, we show that our results obtained with PMC are reliable and robust. The variability in the evidence evaluation and the stability for various cases are estimated both from simulations and from data. For the cases we consider, the log-evidence is calculated with a precision of better than 0.08. Using a combined set of recent CMB, SNIa and BAO data, we find inconclusive evidence between flat LambdaCDM and simple dark-energy models. A curved Universe is moderately to strongly disfavoured with respect to a flat cosmology. Using physically well-motivated priors within the slow-roll approximation of inflation, we find a weak preference for a running spectral index. A Harrison-Zel'dovich spectrum is weakly disfavoured. With the current data, tensor modes are not detected; the large prior volume on the tensor-to-scalar ratio r results in moderate evidence in favour of r=0.

Non-linear bending of beams of variable cross-section

For the non-linear bending of cantilever beams of variable cross-section, the effect of large deformations, but with linear elasticity, is considered. The governing integral equation is solved by a numerical iterative procedure. Results for some typical cases are obtained and compared with some of those available in the literature.

Homologous pairing between nucleosome cores on a linear duplex DNA and nucleoprotein filaments of RecA protein-single stranded DNA

The ability of E coli recA protein to promote homologous pairing with linear duplex DNA bound to HU protein (Nucleosome cores) was found to be differentially affected. The formation of paranemic joint molecules was not affected whereas the formation of plectomic joint molecules was inhibited from the start of the reaction. The formation of paranemic joint molecules between nucleoprotein filaments of recA protein-circular single stranded DNA and closed circular duplex DNA is believed to generate positive supercoiling in the duplex DNA. We found that the positively superhelical duplex DNA was inert in the formation of joint molecules but could be converted into an active substrate, in situ, by the action of wheat germ topoisomerase I. These observations initiate an understanding of the structural features of E coli chromosome such as DNA supercoiling and nucleosome-like structures in homologous recombination.

Suicidal ideation and attempts among psychiatric patients with major depressive disorder

This study is part of an ongoing collaborative research and development project, the Vantaa Depression Study (VDS), between the National Public Health Institute, Helsinki and the Department of Psychiatry of Helsinki University Hospital (HUCH), Peijas hospital, Vantaa. The VDS is a prospective, naturalistic cohort study of 269 secondary-level care psychiatric out- and inpatients with a new episode of DSM-IV major depressive disorder (MDD). 269 patients (Nmales=72, Nfemales=197) with a current DSM-IV MDD were interviewed with semistructured interviews to assess all other psychiatric diagnoses. At 6- and 18-month follow-up the interviews were repeated. Suicidal behaviour was investigated both at intake and follow-up by using a psychometric scale (Scale for Suicidal Ideation) and interviewer's questions as well as the patient's psychiatric records. Patients, who reported suicidal ideation while entering the study were followed up weekly, and their level of suicidal ideation, hopelessness, anxiety and depression was measured. In this study suicidal ideation was common among psychiatric patients with MDD. Almost 60% of the depressed patients reported suicidal ideation and 15% of patients attempted suicide at the baseline. Patients with suicidal ideation or attempts had a clearly higher level of overall psychopathology than non-suicidal patients. During the 18-month follow-up period 8% of patients attempted suicide. The risk of an attempt was markedly higher (RR=7.54) during an episode of major depression compared with a period of remission. Suicide attempt during the follow-up period was predicted by lack of partner, a history of previous suicide attempts and time spent in depression. Suicidal ideation resolved for most of the suicidal patients during the first 2 to 3 months. The duration of suicidal ideation was longer for patients with an initially higher level of psychopathology. Declines both in depression and hopelessness independently predicted the subsequent decline in suicidal ideation. They both could have a causal role in reversing the suicidal process. Thus effective treatment of depression is a credible measure in suicide prevention. Patients with suicidal behaviour often received more antidepressants and had more frequent appointments with mental health professionals than non-suicidal patients. Suicidal patients had also more favourable attitudes towards antidepressant treatment and comparable adherence to treatment than those not suicidal. This study does not support the conception that patient attitudes or adherence to treatments would be a factor differentiating suicidal patients from non-suicidal. Instead, problems with adherence or attitudes seem to be generic to all psychiatric care.

Factors associated with self-reported driver sleepiness and incidents in city bus drivers

Driver fatigue has received increased attention during recent years and is now considered to be a major contributor to approximately 15–30% of all crashes. However, little is known about fatigue in city bus drivers. It is hypothesized that city bus drivers suffer from sleepiness, which is due to a combination of working conditions, lack of health and reduced sleep quantity and quality. The overall aim with the current study is to investigate if severe driver sleepiness, as indicated by subjective reports of having to fight sleep while driving, is a problem for city based bus drivers in Sweden and if so, to identify the determinants related to working conditions, health and sleep which contribute towards this. The results indicate that driver sleepiness is a problem for city bus drivers, with 19% having to fight to stay awake while driving the bus 2–3 times each week or more and nearly half experiencing this at least 2–4 times per month. In conclusion, severe sleepiness, as indicated by having to fight sleep during driving, was common among the city bus drivers. Severe sleepiness correlated with fatigue related safety risks, such as near crashes.

Ductile deformation of single inclusions in simple shear with a finite-strain hyperelastoviscoplastic rheology

We examine the 2D plane-­strain deformation of initially round, matrix-­bonded, deformable single inclusions in isothermal simple shear using a recently introduced hyperelastoviscoplastic rheology. The broad parameter space spanned by the wide range of effective viscosities, yield stresses, relaxation times, and strain rates encountered in the ductile lithosphere is explored systematically for weak and strong inclusions, the effective viscosity of which varies with respect to the matrix. Most inclusion studies to date focused on elastic or purely viscous rheologies. Comparing our results with linear-­viscous inclusions in a linear-­viscous matrix, we observe significantly different shape evolution of weak and strong inclusions over most of the relevant parameter space. The evolution of inclusion inclination relative to the shear plane is more strongly affected by elastic and plastic contributions to rheology in the case of strong inclusions. In addition, we found that strong inclusions deform in the transient viscoelastic stress regime at high Weissenberg numbers (≥0.01) up to bulk shear strains larger than 3. Studies using the shapes of deformed objects for finite-­strain analysis or viscosity-­ratio estimation should establish carefully which rheology and loading conditions reflect material and deformation properties. We suggest that relatively strong, deformable clasts in shear zones retain stored energy up to fairly high shear strains. Hence, purely viscous models of clast deformation may overlook an important contribution to the energy budget, which may drive dissipation processes within and around natural inclusions.

Microstructural evolution during laser resolidification of Fe-25 atom percent Ge alloy

The microstructural evolution of concentrated alloys is relatively less understood both in terms of experiments as well as theory. Laser resolidification represents a powerful technique to study the solidification behavior under controlled growth conditions. This technique has been utilized in the current study to probe experimentally microstructural selection during rapid solidification of concentrated Fe-25 atom pct Ge alloy. Under the equilibrium solidification condition, the alloy undergoes a peritectic reaction between ordered alpha(2) (B2) and its liquid, leading to the formation of ordered hexagonal intermetallic phase epsilon (DO19). In general, the as-cast microstructure consists of epsilon phase and e-p eutectic and alpha(2) that forms as a result of an incomplete peritectic reaction. With increasing laser scanning velocity, the solidification front undergoes a number of morphological transitions leading to the selection of the microstructure corresponding to metastable alpha(2)/beta eutectic to alpha(2) dendrite + alpha(2)/beta eutectic to alpha(2) dendrite. The transition velocities as obtained from the experiments are well characterized. The microstructural selection is discussed using competitive growth kinetics.

Oncolytic Adenoviruses with Radiation Therapy for Treatment of Prostate Cancer

Prostate cancer is the most common cancer in males. Although many patients with localized disease can be cured with surgery and radiotherapy, advanced disease and especially castration resistant metastatic disease remains incurable, with a median life expectancy of less than 18 months. Oncolytic adenoviruses (Ads) are a new promising treatment against cancer due to their innate capacity to kill cancer cells. Viral replication in tumor cells leads to oncolysis and production of a multiplicity of new virions that are capable of further destroying cancerous tissue. Oncolytic Ads can be modified for tumor targeted infection and replication and be armed with therapeutic transgenes to maximize the oncolytic effect. Worldwide, clinical trials with oncolytic Ads have demonstrated good safety while the antitumor efficacy remains to be improved. Importantly, the best responses have been reported when oncolytic adenoviruses have been combined with standard cancer treatments, such as chemotherapy and radiation. Further, a challenge in many virotherapy approaches has been the monitoring of virus replication in vivo. Reporter genes have been extensively used as transgenes to evaluate the biodistribution of the virus and activity of specific promoters. However, these techniques are often limited to preclinical evaluation and not amenable to human use. The aim of the thesis was to find and develop new oncolytic Ads with maximum efficacy against metastatic, castration resistant prostate cancer and study them in vitro and in vivo combined to different forms of radiation therapy. Using combination therapy, we were aiming for better antitumor efficacy with reduced side effects. Capsid modified Ads for enhanced transduction were studied. Serotype 3 targeted chimera, Ad5/3, was found to have enhanced infectivity for prostate cancer and was used for developing new viruses for the study. Correlation between Ad-encoded marker peptide secretion and simultaneous viral replication was evaluated and the effects of radiotherapy on viral replication were studied in detail. We found that the repair of double strand breaks caused by ionizing radiation was inhibited by adenoviral proteins and led to autophagic cell death. Both subcutaneous models and intrapulmonary tumor models mimicking metastatic, aggressive disease were used in vivo. Virus efficacy was evaluated by intratumoral injections. Also, intravenous administration was evaluated to study the effectiveness in metastatic disease. Oncolytic adenovirus treatment led to significant tumor growth control and increased the survival rate of the mice. These results were further improved when oncolytic Ads were combined with radiation therapy. Oncolytic Ads expressing human sodium/iodide transporter (hNIS) as a transgene were evaluated for their oncolytic potency and for the functionality of hNIS in vitro and in vivo. Monitoring of viral replication was also assessed using different imaging modalities relative to clinical use. SPECT imaging of tumor-bearing mice was evaluated and combined with simultaneous CT-scanning to obtain important anatomical information on biodistribution, also in a three-dimensional form. It was shown that hNIS-expressing adenoviruses could harbour a bi-functional transgene allowing for localization and imaging of viral replication. Targeted radiotherapy was applied by systemic radioiodide administration and resulted in iodide accumulation into Ad-infected tumor. The combination treatment showed significantly enhanced antitumor efficacy in mice bearing prostate cancer tumors. In summary, the results presented above aim to provide new treatment modalities for castration resistant prostate cancer. Molecular insights were provided for better understanding of the benefits of combined radiation therapy and oncolytic adenoviruses, which will hopefully facilitate the translation of the approach into clinical use for humans.

Elimination of common mode voltage and fifth and seventh harmonics in a multilevel inverter fed IM drive using 12-sided polygonal voltage spacephasor

A multilevel inverter with 12-sided polygonal voltage space vector structure is proposed in this paper. The present scheme provides elimination of common mode voltage variation and 5(th) and 7(th) order harmonics in the entire operating range of the drive. The proposed multi level structure is achieved by cascading only the conventional two-level inverters with asymmetrical DC link voltages. The bandwidths problems associated with conventional hexagonal voltage space vector structure current controllers, due to the presence of 5(th) and 7(th) harmonics, in the over modulation region, is absent in the present 12-sided structure. So a linear voltage control up to 12-step operation is possible, from the present twelve sided scheme, with less current control complexity. An open-end winding structure is used for the induction motor drive.

Low temperature processing and chacterization of SrBi2Nb2O9 thin films grown by pulsed laser ablation

Ex-situ grown thin films of SrBi2Nb2O9 (SBN) were deposited on platinum substrates using laser ablation technique. A low substrate-temperature-processing route was chosen to avoid any diffusion of bismuth into the Pt electrode. It was observed that the as grown films showed an oriented growth along the 'c'-axis (with zero spontaneous polarization). The as grown films were subsequently annealed to enhance crystallization. Upon annealing, these films transformed into a polycrystalline structure, and exhibited excellent ferroelectric properties. The switching was made to be possible by lowering the thickness without losing the electrically insulating behavior of the films. The hysteresis results showed an excellent square-shaped loop with results (P-r = 4 muC/cm(2) E-c = 90 kV/cm) in good agreement with the earlier reports. The films also exhibited a dielectric constant of 190 and a dissipation factor of 0.02, which showed dispersion at low frequencies. The frequency dispersion was found to obey Jonscher's universal power law relation, and was attributed to the ionic charge hopping process according to earlier reports. The de transport studies indicated an ohmic behavior in the low voltage region, while higher voltages induced a bulk space charge and resulted in non-linear current-voltage dependence.

Lahopuumäärän ennustaminen ja kartoitus lentokonelaserkeilauksen avulla

Lahopuun määrästä ja sijoittumisesta ollaan kiinnostuneita paitsi elinympäristöjen monimuotoisuuden, myös ilmakehän hiilen varastoinnin kannalta. Tutkimuksen tavoitteena oli kehittää aluepohjainen laserkeilausdataa hyödyntävä malli lahopuukohteiden paikantamiseksi ja lahopuun määrän estimoimiseksi. Samalla tutkittiin mallin selityskyvyn muuttumista mallinnettavan ruudun kokoa suurennettaessa. Tutkimusalue sijaitsi Itä-Suomessa Sonkajärvellä ja koostui pääasiassa nuorista hoidetuista talousmetsistä. Tutkimuksessa käytettiin harvapulssista laserkeilausdataa sekä kaistoittain mitattua maastodataa kuolleesta puuaineksesta. Aineisto jaettiin siten, että neljäsosa datasta oli käytössä mallinnusta varten ja loput varattiin valmiiden mallien testaamiseen. Lahopuun mallintamisessa käytettiin sekä parametrista että ei-parametrista mallinnusmenetelmää. Logistisen regression avulla erikokoisille (0,04, 0,20, 0,32, 0,52 ja 1,00 ha) ruuduille ennustettiin todennäköisyys lahopuun esiintymiselle. Muodostettujen mallien selittävät muuttujat valittiin 80 laserpiirteen ja näiden muunnoksien joukosta. Mallien selittävät muuttujat valittiin kolmessa vaiheessa. Aluksi muuttujia tarkasteltiin visuaalisesti kuvaamalla ne lahopuumäärän suhteen. Ensimmäisessä vaiheessa sopivimmiksi arvioitujen muuttujien selityskykyä testattiin mallinnuksen toisessa vaiheessa yhden muuttujan mallien avulla. Lopullisessa usean muuttujan mallissa selittävien muuttujien kriteerinä oli tilastollinen merkitsevyys 5 % riskitasolla. 0,20 hehtaarin ruutukoolle luotu malli parametrisoitiin muun kokoisille ruuduille. Logistisella regressiolla toteutetun parametrisen mallintamisen lisäksi, 0,04 ja 1,0 hehtaarin ruutukokojen aineistot luokiteltiin ei-parametrisen CART-mallinnuksen (Classification and Regression Trees) avulla. CARTmenetelmällä etsittiin aineistosta vaikeasti havaittavia epälineaarisia riippuvuuksia laserpiirteiden ja lahopuumäärän välillä. CART-luokittelu tehtiin sekä lahopuustoisuuden että lahopuutilavuuden suhteen. CART-luokituksella päästiin logistista regressiota parempiin tuloksiin ruutujen luokituksessa lahopuustoisuuden suhteen. Logistisella mallilla tehty luokitus parani ruutukoon suurentuessa 0,04 ha:sta(kappa 0,19) 0,32 ha:iin asti (kappa 0,38). 0,52 ha:n ruutukoolla luokituksen kappa-arvo kääntyi laskuun (kappa 0,32) ja laski edelleen hehtaarin ruutukokoon saakka (kappa 0,26). CART-luokitus parani ruutukoon kasvaessa. Luokitustulokset olivat logistista mallinnusta parempia sekä 0,04 ha:n (kappa 0,24) että 1,0 ha:n (kappa 0,52) ruutukoolla. CART-malleilla määritettyjen ruutukohtaisten lahopuutilavuuksien suhteellinen RMSE pieneni ruutukoon kasvaessa. 0,04 hehtaarin ruutukoolla koko aineiston lahopuumäärän suhteellinen RMSE oli 197,1 %, kun hehtaarin ruutukoolla vastaava luku oli 120,3 %. Tämän tutkimuksen tulosten perusteella voidaan todeta, että maastossa mitatun lahopuumäärän ja tutkimuksessa käytettyjen laserpiirteiden yhteys on pienellä ruutukoolla hyvin heikko, mutta vahvistuu hieman ruutukoon kasvaessa. Kun mallinnuksessa käytetty ruutukoko kasvaa, pienialaisten lahopuukeskittymien havaitseminen kuitenkin vaikeutuu. Tutkimuksessa kohteen lahopuustoisuus pystyttiin kartoittamaan kohtuullisesti suurella ruutukoolla, mutta pienialaisten kohteiden kartoittaminen ei onnistunut käytetyillä menetelmillä. Pienialaisten kohteiden paikantaminen laserkeilauksen avulla edellyttää jatkotutkimusta erityisesti tiheäpulssisen laserdatan käytöstä lahopuuinventoinneissa.

Variable Elimination in Linear Constraints

Gauss and Fourier have together provided us with the essential techniques for symbolic computation with linear arithmetic constraints over the reals and the rationals. These variable elimination techniques for linear constraints have particular significance in the context of constraint logic programming languages that have been developed in recent years. Variable elimination in linear equations (Guassian Elimination) is a fundamental technique in computational linear algebra and is therefore quite familiar to most of us. Elimination in linear inequalities (Fourier Elimination), on the other hand, is intimately related to polyhedral theory and aspects of linear programming that are not quite as familiar. In addition, the high complexity of elimination in inequalities has forces the consideration of intricate specializations of Fourier's original method. The intent of this survey article is to acquaint the reader with these connections and developments. The latter part of the article dwells on the thesis that variable elimination in linear constraints over the reals extends quite naturally to constraints in certain discrete domains.

Enhanced efficiency of tri-layered dye solar cells with hydrothermally synthesized titania nanotubes as light scattering outer layer

In the present study dye sensitized solar cells (DSSCs) have been fabricated with a tri-layer photo anode consisting of hydrothermally prepared titania nano tubes (TNT) having a diameter of 9-10 nm and length of several micrometers as outer layer, P25 TiO2 powder as transparent light absorbing middle layer and a compact TiO2 inner layer to improve the adhesion of different layers on a transparent conducting oxide coated substrate. In comparison to cells fabricated using TNTs or P25 alone, the tri-layer DSSCs exhibit an enhanced efficiency of 7.15% with a current density of 17.12 mA cm(-2) under AM 1.5 illumination. The enhancement is attributed to the light scattering generated by TNTs aggregates, reduction in electron transport resistance at the TiO2/dye/electrolyte interface and an improvement in electron life-time. (c) 2012 Elsevier B.V. All rights reserved.